<DOCUMENT>
<TYPE>EX-99.77E LEGAL
<SEQUENCE>2
<FILENAME>ex77e.txt
<TEXT>
Regulatory Update

As previously reported in the press, a number of private lawsuits have
been
filed including purported
class action and derivative lawsuits, making various allegations and
naming as defendants various
persons, including certain Scudder funds, the funds' investment advisors
and their affiliates, certain
individuals, including in some cases fund Trustees/Directors, officers,
and
other parties.  Each Scudder
fund's investment advisor has agreed to indemnify the applicable Scudder
funds
 in connection with these
lawsuits, or other lawsuits or regulatory actions that may be filed making
allegations similar to these
lawsuits regarding market timing, revenue sharing, fund valuation or other
subjects arising from or
related to the pending inquiries.  Based on currently available information,
the funds' investment advisors
believe the likelihood that the pending lawsuits will have a material
adverse
financial impact on a
Scudder fund is remote and such actions are not likely to materially affect
their
ability to perform under
their investment management agreements with the Scudder funds.

The following purported class action lawsuits have been filed:

(1) On September 16, 2003, in the Circuit Court for Madison County, Illinois
entitled Potter v. Janus
Investment Fund, et al.  Defendants include, among others, Deutsche
Investment
Management Americas
("DIMA"), Inc., and Scudder International Fund.  On May 27, 2005 the Northern
District of Illinois
Court in accord with the 7th Circuit's mandate dismissed the state law claims
with prejudice.  (2) On
May 12, 2004, in the United States District Court for the Southern District
 of
New York entitled Icardo
v. Deutsche Bank AG, et al.  Defendants include, among others, Deutsche Bank
 AG,
DeAM, DIMA,
Scudder Investments, Scudder Funds, and certain Directors/Trustees of the
Scudder
 Funds.  (3) On
September 29, 2004, the following complaint, In re Mutual Funds Investment
Litigation, consolidating
the previously filed class action lawsuits was filed in conjunction with the
multi-district litigation panel
sitting in the United States District Court for the District of Maryland.
The
defendants include the
Scudder Funds, their Directors/Trustees and Officers and former
Directors/Trustees
and Officers,
Deutsche Bank AG and certain investment adviser affiliated, employees and
former
employees.

The following derivative lawsuit was filed:

On September 29, 2004, the following complaint, Hinton v. Deutsche Bank AG,
et al., consolidating
the previously filed class action lawsuits was filed in conjunction with the
multi-district litigation panel
sitting in the United States District Court for the District of Maryland.
The
defendants include the
Scudder Funds, their Directors/Trustees and Officers and former
Directors/Trustees
 and Officers,
Deutsche Bank AG and certain investment adviser affiliated, employees and
former
employees.

The following combined purported class action and derivative lawsuits have
been filed:

(1) On March 10, 2004, in the United States District Court for the Southern
District
of New York
entitled Walker v. Deutsche Bank AG, et al.  Defendants include, among others,
Deutsche
Bank AG,
DeAM, DIMA, Scudder Investments, and certain Directors/Trustees of the Scudder
 funds.
 (2) On
May 6, 2004, in the United States District Court for the Southern District of
New York
entitled Mazza
v. Deutsche Bank AG, et al.  Defendants include, among others, Deutsche Bank
 AG,
 DeAM,
 DIMA,
Scudder Investments, and certain Directors/Trustees of the Scudder funds.


In addition to the market timing, revenue sharing and valuation litigation
 discussed
above  the following
unrelated purported class action lawsuit has been filed:

On January 12, 2005, in the United States District Court for the Southern
District
of New
York entitled
McMunn and Raimo v. Deutsche Bank Americas Holding Corporation, et al.
Defendants
 include
among others, Deutsche Bank Americas Holding Corporation, DeAM, Inc., Scudder
Investors
Services, Inc., and certain Directors/Trustees of the Scudder Funds.  The
lawsuit
 alleges
 the defendants
breached their fiduciary duties and violated the Investment Company Act of
1940 by
failing
to collect
settlement funds awarded in investor class action lawsuits for securities held
by the
 Scudder Funds.

Based on currently available information, the funds' investment advisors
believe
the
likelihood that this
January 12, 2005 pending lawsuit will have a material adverse financial impact
 on a
Scudder
fund is
remote and such action is not likely to materially affect their ability to
perform
under their
 investment
management agreements with the Scudder funds.


G:\mfld\market timers\Disclosure - Litigation\77e disclosure _ 1-21-05.doc
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